Din l-Art Helwa comments on the formulation of ODZ policy objectives

Din l-Art Helwa comments on the formulation of ODZ policy objectives by the Malta Environment and Planning Authority

16^th September 2013

1. Din l-Art Helwa reiterates its position that the 2-week public consultation period for the formulation of these important objectives for Malta’s ODZ policy was not adequate to ensure full public participation. It is unacceptable that DLH’s request for an extension of this consultation period was refused by MEPA without justification.

2. The primary and overriding emphasis of all ODZ policy must be to safeguard and protect the rural environment as a precious resource, and to counteract the urban sprawl into the countryside. The main emphasis must be on the protection of rural landscapes, ecosystems and biodiversity. ODZ policies must highlight the conservation and restoration of all natural habitats in ODZ areas, and safeguard them against pressures from development.

3. DLH contends that absolutely no development should be allowed in ODZ areas if such development may be carried out within building areas. For example, no further schools, homes for the elderly, residences, social housing, open storage, or petrol stations should be allowed in ODZ areas. If any ODZ development is permitted, such as a farm, the site must be reinstated once the site is no longer used for the permitted purpose. No changes of use should be allowed.

4. The degradation of ODZ land should never be accepted as a justification for development on vacant land, as this encourages blatant abuse.

5. No livestock farms should be allowed in pristine countryside areas. All farms should be guided to the least sensitive ODZ areas.

6. Agritourism facilities must be limited to genuine farm-related activities and accommodation should be guided towards nearby villages and existing old farmhouse buildings.

7. Vernacular rural architecture and old agricultural features in the countryside should be protected, including their context.

8. All land which can be cultivated as arable land should be protected from development. The fact that the land is not cultivated at present should not be accepted as a justification to use it for development. The fragmentation of agricultural land must be avoided.

9. ODZ policy should actively promote rainwater harvesting, and the closure of all illegal boreholes.

10. All recreational areas in the countryside should respect the landscape character of the site.

11. ODZ policy should seek to avoid all forms of light pollution in rural areas, including from roads.

12. ODZ policy should promote the removal of inappropriate or illegal development from the countryside, and actively discourage its use, re-development or sanctioning.

13. ODZ policy should actively encourage afforestation projects in appropriate areas.

14. ODZ policy should take into account all relevant measures from the National Environment Policy (2012) and the National Biodiversity Strategy and Action Plan (2012).

15. ODZ policy should actively promote a high level of design in all aspects.

16. ODZ policy should encourage the reuse and recycling of limestone, ensure the protection of soil as an important resource, and promote measures to avoid soil erosion and soil sealing.

17. “PV farms” should be excluded from all ODZ areas where they present a visual intrusion in the rural landscape, and from all sensitive ODZ areas.

18. Nature trails in the countryside, and wide public access to the countryside, should be encouraged.

19. ODZ policy should encourage the creation and implementation of environmental management plans for ODZ areas.